Respondent has a liquid natural gas pretreatment process at the Facility, meeting the definition of ” process” as defined by 40 C.F.R. § 68.3. Respondent receives natural gas by pipeline and pretreats the natural gas to remove carbon dioxide, sulfur compounds, water, mercury, and heavy hydrocarbons. The regulated substance under 40 C.F.R. Part 68 Chemical Accident RMP regulations is Natural Gas Liquid (NGL) condensate, a mixture of regulated flammable gas hydrocarbons. The components of the NGL condensate are present at or above the minimum threshold for RMP applicability. NGL condensate is comprised of varying percentages of methane, ethane, propane, and pentane, each of which are flammable substances (the “Regulated Flammable Substance”s). As a result, Respondent produces, processes, handles, and stores the Regulated Flammable Substances at the Facility. Respondent has greater than a threshold quantity of the Regulated Flammable Substances in a process at the Facility, meeting the definition of”covered process” as defined by 40 C.F.R. § 68.3.
EPA Findings of Violation